Also serving the communities of De Luz, Rainbow, Camp Pendleton, Pala and Pauma

FPUD's trucking of water doesn't meet health law

An “Evidentiary Hearing” for Orange Grove Power Plant’s (OGP) “Application for Certification” was held at the Pala Mesa Resort on December 19.

My status as an “Intervenor” permitted me to present evidence that must be considered by (California’s) Energy Resources Conservation and Development Commission (CERCDC).

Only evidence presented by “Intervenors,” the applicant and the California Energy Commission (CEC) is/was permitted by the commissioners. Comments by the general public were invited but not considered as evidence.

At this meeting, I was formally recognized by the CERCDC as an expert witness in water and wastewater. OGP did not contest this status.

The transportation of water/wastewater by tanker truck from Fallbrook to the OGP was hotly discussed. Total water weight for the designated 6,500-gallon tank is 55,510 lbs.

This is the first power plant in history using truck transportation for its potable and reclaimed/recycled water. Contracts between OGP and FPUD are for 25 years plus two months.

Evidence was provided that FPUD’s reclaimed water cannot meet California Health Laws Related to Recycled Water (CHLRRW) for “Disinfected tertiary recycled water (DTRW)” usage.

DTRW has much higher personnel health qualities than FPUD’s reclaimed water.

Title 22, June 2001 Edition, Section 60301 of the CHLRRW for “Industrial Process Water that may come in contact with workers” requires DTRW.

Reclaimed water must be transported in purple piping and labeled “Contaminated: Do not drink” per CHLRRW, Section 13555.3, not in tank trucks (more restrictive industry requirements).

Archie McPhee


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